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EPA Denies Petition to Stop Cyanide Use that Is Killing Wildlife

(Beyond Pesticides, December 5, 2018)  The Environmental Protection Agency (EPA) has denied a petition seeking to ban M-44s — cyanide-spraying apparatuses used to kill coyotes, foxes, and wild dogs that may prey on livestock. Submitted to the EPA in August 2017 by the Center for Biological Diversity, WildEarth Guardians, the Humane Society of the U.S., Natural Resources Defense Council,Predator Defense, the Sierra Club, and a number of other conservation, wildlife, and environmental organizations, the petition sought cancellation of the registration of cyanide capsules used in M-44s and a functional ban on their use in the “lower 48” states because of their danger to non-target wildlife, domestic pets, and people. In its letter of denial, EPA noted that it “is currently reviewing these products using the Registration Review process and sees no reason, and the Petition provides none, to start a parallel process using Special Review proceedings to look at the same issues.”

Although the word “pesticide” generally conjures thoughts of a chemical meant to kill insect “pests,” whether sprayed on crops, coated onto seeds, or in the kit bag of an “exterminator” whose business it is to rout out some infestation in a home or building, these two compounds — sodium cyanide (used in M-44s) and the so-called “compound 1080,” another chemical employed on wildlife — qualify for the term. They are chemical approaches to “controlling” organisms considered by some to be “pests” — those whose presence and activity are deemed inconvenient or destructive to some economic interests.

For M-44s and compound 1080, those target organisms are coyotes, foxes, and wild dogs, which are regarded by ranchers as threats because they sometimes prey on livestock. These chemicals represent public safety and health risks, at the very least. The sodium cyanide capsules used in m-44s are triggered to burst when touched, and will spray the poison up to five feet from the device — into the mouths of animals that are attracted to the devices by odoriferous bait, and then may be killed or injured by the cyanide. The chemical is produced from dangerous hydrogen cyanide gas, and has both acute and long-term effects. Acute impacts of low-dose ingestion or inhalation include nausea, vomiting, tachycardia, headache, and dizziness; larger-volume exposure via any route can cause loss of consciousness, injury to lungs, hypotension, bradycardia, convulsions, and respiratory failure that can lead to death. Longer-term health effects in survivors of poisoning may include cardiac and neurological damage.

Compound 1080 is used legally in the U.S. only in “livestock protection collars,” which are worn on domestic animals’ necks. The toxic chemical is ingested if a predator, such as a coyote, pierces the collar while attempting to take down the animal. The use of these collars is administered by the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service’s Wildlife Services program, which allows them in Idaho, Montana, New Mexico, South Dakota, Texas, Utah, West Virginia, and Wyoming. Compound 1080 (sodium fluoroacetate or sodium monofluoroacetate) is a water-soluble, odorless, colorless, tasteless, and lethally toxic poison with no antidote; a single teaspoon could kill as many as 100 adult humans. It causes basic cellular process to fail, leading to gross organ failure and a very painful death.

Compound 1080 has a 70-year history in the U.S.: it was introduced in the late 1940s for rodent and coyote control, but was banned by President Nixon in 1972 because of its unintended lethality for grizzly bears, eagles, and hawks. In 1985, the Reagan administration EPA overturned the ban and approved the use of poisoned collars on sheep and goats. The Tull Chemical Company in Oxford, Alabama is the only legal producer of the compound in the U.S.; most of its product is exported to New Zealand, where it is used to control populations of opossums, rats, stoats, deer, and rabbits, which there are invasive species.

Also in 2017, a group of advocate organizations acted on compound 1080, petitioning EPA to issue “a Notice of Intent to Cancel the registration of sodium fluoroacetate (commonly known as ‘Compound 1080’ or sodium monofluoroacetate), a toxicant registered for use in ‘livestock protection collars.’” The petition noted that “Cancellation of a pesticide’s registration is warranted where the ‘pesticide or its labeling or other material required to be submitted does not comply with the provisions of [FIFRA Subchapter II] or, when used in accordance with widespread and commonly recognized practice, generally causes unreasonable adverse effects on the environment.’ Here, the registration must be suspended because EPA has not made the necessary finding, after public notice and comment, that coyotes are ‘pests,’ and as such, use of Compound 1080 to kill coyotes (Canis latrans) does not comply with the provisions of FIFRA, Subchapter II.3.” Co-petitioners included the Animal Welfare Institute, the Animal Legal Defense Fund, the Center for Biological Diversity, Project Coyote, and Predator Defense. There has not yet been a publicly available response to this petition.

Both of these petition efforts followed by a decade the submission of an earlier request to the EPA by Beyond Pesticides, Public Employees for Environmental Responsibility (PEER), Forest Guardians, Predator Defense, Western Wildlife Conservancy, the Sierra Club, and several other animal welfare groups, asking that the agency issue a Notice of Intent to Cancel the registration of both M-44 sodium cyanide capsules and compound 1080.

The 2017 petition on M-44s, now denied by the EPA, followed events in that same year in which the devices temporarily blinded a child and killed three pet dogs in two different incidents (in Idaho and Wyoming). A wolf was also accidentally killed by an M-44 in Oregon in 2017. Shortly after that spate of incidents, Representative Peter DeFazio of Oregon re-introduced legislation — The Chemical Poisons Reduction Act of 2017 — on which Predator Defense has been working for years, to ban the uses of compound 1080 and M-44s with cyanide capsules in predator control efforts.

The number of animals killed by compound 1080 is unclear. Wildlife Services set it at 26 for 2010, but Predator Defense claims that number is likely “grossly underestimated, and that Wildlife Services actively covers up non-target kills, especially the deaths of pets and endangered species.” The organization also says that M-44s cause 10,000–15,000 animal deaths annually, with an unknown number of those being domestic pet dogs. According to Wildlife Services, M-44s killed 13,232 animals in 2017; most were coyotes and foxes, but more than 200 were nontarget animals (a wolf, pet dogs, opossums, raccoons, ravens, and skunks). According to the Sacramento Bee, 18 Wildlife Services employees (and several other people) were exposed to cyanide by M-44s from 1987 through 2012, and during the 2000–2012 period, the devices killed more than 1,100 dogs. National Geographic further reports that of 76,963 coyotes killed in 2016 for livestock protection, 12,511 were felled with M-44s, and that Wildlife Services spends more than $120 million a year killing animals deemed “nuisances” to humans.

On Wildlife Services accounting, the Center for Biological Diversity (CBD) notes, “Unfortunately these numbers are likely a significant undercount of the true death toll, as Wildlife Services is notorious for poor data collection and an entrenched ‘shoot, shovel, shut up’ mentality.” Advocates against these chemical killers of wildlife and domestic animals (never the mind collateral injury to humans) are adamant in their critique. CBD attorney and biologist Collette Adkins said of M-44s, “Cyanide traps are indiscriminate killers that just can’t be used safely. We’ll keep fighting for a permanent nationwide ban, which is the only way to protect people, pets and imperiled wildlife from the EPA’s poison.” Bethany Cotton, wildlife program director for WildEarth Guardians, added, “The government continues to prioritize the minority anti-wildlife ranching industry over making public lands safe for people, imperiled wildlife and companion animals. These dangerous, indiscriminate devices have absolutely no place on public lands, especially given no evidence exists that they actually reduce conflict [between wildlife and livestock].”

Predators are critical components of ecosystems, impacting the food web and regulating the effects other animals have on ecosystems — the very ecosystems that provide massive environmental and other benefits to humans. Read more about Beyond Pesticides work on issues that impact wildlife, and consider advocating with U.S. Representatives and Senatorsfor legislation banning M-44s and compound 1080, such as H.R. 1817.

All unattributed positions and opinions in this piece are those of Beyond Pesticides.


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